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CASE FILE · EXHIBIT 03

EXHIBIT 03 · FILED AUGUST 2026

THE MISSING LINK

Three cases from one marketing world

Between 2018 and 2021, three enforcement stories came out of the same online marketing economy: a coaching company called MOBE, a Baltimore publishing empire, and one marketer. Same era. Same toolkit of funnels, testimonials, and traffic. Three very different endings. One person is documented inside two of these worlds at the same time.

Presentation note: the MOBE and Agora matters were civil; every settlement in them was entered without admission of liability, and the cases differed in scale and legal posture. Only the third case ended in a guilty plea. This exhibit places the documented outcomes side by side. It asserts no motive. Read it and draw your own conclusions.

EXHIBIT 03-A

Three dockets

Civil · FTC

FTC v MOBE Ltd

M.D. Fla. · filed June 2018 · "My Online Business Education"

  • The claim: more than $125 million taken from consumers via a $49-entry, 21-step coaching ladder rising into the tens of thousands.
  • The targets: service members, veterans, older adults, students, teenagers, per the FTC.
  • Day one: restraining order, assets frozen, receiver installed, websites dark.
  • The founder: Matt Lloyd McPhee, default judgment of $318,512,336, a figure reflecting alleged total consumer harm; actually surrendered $16M+ including a Fijian island, a Costa Rican resort, and Kuala Lumpur apartments; banned from the industry for life. The FTC later returned $23M+ to consumers.
  • The refunds: $23M+ returned to 37,397 consumers, average just over $633.
COMPANY: ERASED
Civil · FTC

FTC v Agora Financial

D. Md. · filed October 2019 · two promotions at issue

  • The claim: deceptive health and money-making promotions aimed at seniors: a diabetes "cure" and a government-checks pitch.
  • The fight: the publisher litigated, won a narrower injunction, then settled by stipulated order in February 2021.
  • The money: $2,052,868 refunded to 34,893 consumers. No admission of liability. No fine beyond the refunds, per the company.
  • The people: two editors named. No owner, no marketer, no affiliate.
  • After: the company kept publishing; a separate Baltimore civil suit filed June 2026 is pending.
COMPANY: OPERATING
Criminal · DOJ

USA v Arrington

D. Md. · indicted June 2019 · the marketer

  • The claim: unauthorized charges on his employer's card while working as the SEO specialist inside the publisher's Money Map Press unit, roughly 2011 to August 2018.
  • The plea: guilty, wire fraud conspiracy, February 2020.
  • The sentence: 30 months federal prison plus 12 months home confinement.
  • The debt: restitution of $4,142,435.31, to the dollar.
  • The distinction: the only individual in this exhibit to face criminal charges, and the only one who went to prison.
MARKETER: IMPRISONED
EXHIBIT 03-B

The scale, in their own numbers

Judgment against MOBE's founder

$0

FTC stipulated order, 2020 · civil · settled, no admission

Refunds in the publisher's FTC case

$0

FTC, November 2021 · 34,893 consumers · civil · no admission

Restitution owed by the marketer

$0

DOJ sentencing, D. Md. · criminal · guilty plea

Three numbers from three official records. The differences in scale are real: the FTC alleged $125M+ in MOBE consumer harm, while its Agora case concerned two promotions. *The MOBE figure is a default judgment reflecting alleged total consumer harm, not an amount collected: defendants surrendered $16M+ in settlements and the FTC returned $23M+ to consumers. The exhibit reports the outcomes; it does not claim the cases were legally identical.

EXHIBIT 03-C

Who was named, person by person

Marketing operators pursued by name · MOBE's world

Michael Giannulis & Michael Williams, affiliates$31.6M judgment, suspended on $760,000
Gar Leong Chow, affiliate$3,350,000, paid in full
Steven Bransfield, affiliate$4.7M, suspended
Scott Zuckman, affiliate$1.8M, partially suspended
Matt Lloyd McPhee, founder$318,512,336*
QualPay, payment processor$46.7M, suspended

"Affiliates should take note that the FTC will hold you personally and financially accountable for false or unsubstantiated marketing claims." · Andrew Smith, Director, FTC Bureau of Consumer Protection, March 2020. All settlements without admission of liability.

Marketing operators pursued by name · the publisher's world

NONE.

No SEO operator, media buyer, copywriter, or affiliate from the publisher's ecosystem was ever named by the FTC. The two individuals named were editors.

The one marketing operator from that world who did face individual accountability was its own SEO specialist, in a criminal case about his employer's card. He is the third docket above.

GAP ON RECORD
EXHIBIT 03-D

The missing link

One inbox, chadmmp@gmail.com, holds both worlds in the same months of 2017 and 2018.

When MOBE fell, the government named the marketers and took their money. When the publisher settled, no marketer was named at all. Chad Arrington is the one marketer documented standing in both worlds, and the only person in this file who went to prison. Who gets held accountable in this industry, for what, and by whom? The record above is the record. The question is yours.

SOURCES: FTC v MOBE Ltd et al, matter 172-3072, M.D. Fla. 6:18-cv-862 (complaint, orders, press releases 2018-2022) · FTC v Agora Financial LLC, matter 182-3116, D. Md. 1:19-cv-03100 (stipulated order Feb 2021; refund release Nov 2021) · U.S. Attorney's Office, District of Maryland, USA v Arrington (plea and sentencing releases) · The Register, Feb 14, 2020 · Documents on file: exhibit index. MOBE and Agora matters were civil and settled without admission of liability. Baltimore v Agora (2026) is a pending civil matter and is not part of this exhibit's findings. Read the documents ›

Earlier context, same network: in 2003 the SEC sued Agora, its subsidiary Pirate Investor, and editor Frank Porter Stansberry over emails selling "inside information" about a stock; after trial, judgment of roughly $1.55 million ran against Pirate Investor and Stansberry only, and Agora Inc. itself was found not liable (affirmed, 4th Cir. 2009). In June 2026 the City of Baltimore filed a pending consumer-protection suit (C-24-CV-26-004112); Agora denies the claims and moved to dismiss on July 30, 2026. The enforcement record around this marketing world spans 2003–2026.
Sources & primary record
Every case in this exhibit, cited
01 · FTC v. MOBE Ltd. (M.D. Fla., filed June 2018) · FTC action; settlement without admission
ftc.gov
02 · DOJ, USAO-MD, indictment release
justice.gov/usao-md/pr/rap-artist-chad-focus-facing-federal-indictment-wire-fraud-conspiracy-and-aggravated
03 · DOJ, U.S. Attorney D. Md., sentencing release
justice.gov/usao-md/pr/rap-artist-chad-focus-sentenced-more-two-years-federal-prison-wire-fraud-conspiracy
04 · Washington Post coverage of the case, June 2019 · per archived URL
washingtonpost.com/local/a-baltimore-rapper-billed-himself-as-self-made-music-sensation-feds-say-his-persona-was-built-on-fraud/2019/06/11/
05 · "How much fraud would it take?" · VICE
vice.com/en/article/chad-focus-wanted-to-be-a-rap-mogul-how-much-fraud-would-it-take/
06 · $2M FTC settlement, phony diabetes "cure" (2021) · FTC
ftc.gov/news-events/news/press-releases/2021/02/publisher-will-pay-more-2-million-settle-ftc-charges-it-targeted-seniors-phony-d
07 · FTC refunds $2.05M to 34,893 consumers (2021) · FTC
ftc.gov/news-events/news/press-releases/2021/11/ftc-sends-full-refunds-totaling-over-2-million-consumers-who-lost-money-through-
08 · Oregon AG settles with Money Map Press · Oregon DOJ (June 2020)
doj.state.or.us/media-home/news-media-releases/ag-rosenblum-settles-with-financial-publishing-company-money-map-press/
09 · Assurance of Voluntary Compliance, Money Map Press · Pennsylvania OAG (June 2020, PDF)
attorneygeneral.gov/wp-content/uploads/2020/06/2020-06-22-AVC-Executed-Money-Map-Press.pdf
10 · SEC v. Pirate Investor / Stansberry (2003, judgment vs. subsidiary only; Agora Inc. not liable) · SEC LR-18090
sec.gov/enforcement-litigation/litigation-releases/lr-18090
11 · Mayor & City Council press release (June 9, 2026)
baltimorecity.gov/mayor/news-media/press-releases/2026-06-09-mayor-brandon-m-scott-and-the-city-council-of-baltimore-take-action-to-halt-a
12 · The Complaint, C-24-CV-26-004112 (PDF) · Relman Colfax
relmanlaw.com/media/cases/2416_Agora%20-%20Complaint.pdf
13 · Agora brand dossier & timeline · Truth in Advertising
truthinadvertising.org/brands/agora/
FTC v. Agora Financial: charges announced 2019; $2M settlement finalized 2021, without admission. Money Map Press itself settled with the Oregon and Pennsylvania AGs in June 2020. All civil matters are allegations or settlements without admission; only U.S. v. Arrington is a criminal conviction.